Khor Chin Lim v. Courtcall Inc., 683 F.3d 378

Plaintiff sued various parties alleging a conspiracy to ruin his life; district court dismissed as fantastical.
Plaintiff had 30 days to appeal but waited almost 90 days.
Plaintiff filed a Rule 4(a)(6) motion to reopen within 180 days after dismissal, arguing he did not receive notice timely.
The district court reopened the time for appeal, then remanded to consider meaning of "receive notice" and honesty of plaintiff's representations.
On remand, the judge concluded plaintiff was abroad but learned of the judgment after returning; the judge revoked the reopening, holding receipt occurred when notice was mailed and delivered.
This court held receipt occurs when the notice is delivered to the proper address, and that delivery here satisfied receipt within 21 days; the appeal was dismissed for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When is notice 'received' for Rule 4(a)(6) purposes?	Plaintiff contends receipt occurs only when envelopes are opened and read.	Defendants contend receipt occurs upon mailing/delivery to the proper address.	Receipt occurs on delivery to the proper address; opening is not required.
Was the district court's revocation of the Rule 4(a)(6) reopening proper?	Plaintiff argues the court should retain the reopening regardless of receipt timing.	Defendant argues the court correctly revoked reopening given proper receipt and jurisdictional limits.	Yes; the district court properly revoked the reopening and the appeal was dismissed for lack of jurisdiction.

Ho v. Donovan, 569 F.3d 677 (7th Cir. 2009) (receipt occurs on delivery to address)
Bowles v. Russell, 551 U.S. 205 (U.S. 2007) (jurisdictional time limits cannot be extended)
Williams v. Washington Convention Center Authority, 481 F.3d 856 (D.C. Cir. 2007) (receipt not equated with service; receipt must occur at address)
Poole v. Family Court of New Castle County, 368 F.3d 263 (3d Cir. 2004) (service by mail completes upon mailing; receipt relevant to notice)